RNP-RA/16-0062, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML16215A376
Person / Time
Site:	Robinson
Issue date:	08/01/2016
From:	Glover R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/16-0062
Download: ML16215A376 (8)

Text

R. Michael Glover H B Robinson Steam Electric Plant Umt 2 Site Vice President Duke Energy Progress 3581 West Entrance Raad Hartsville, SC 29550 0 843 857 1701 F 843 8571319

!tlikt!. G/01*er@"..duke-energy.com 10 CFR 50.4 Serial: RNP-RA/16-0062

~AUG [(J J 2016 United States Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuantto 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

References:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 ADAMS Accession Number ML12053A340

2. NRC Letter, Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 "Seismic" of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated October 27, 2015, ADAMS Accession Number ML15194A015

3. NEI Letter, transmits EPRI 3002007148 for NRC endorsement, dated February 23, 2016, ADAMS Accession Number ML16055A017

4. EPRI 3002007148, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, February 2016

5. NRC Letter, provides endorsement of EPRI 3002007148, dated March 17, 2016, ADAMS Accession Number ML15350A158

6. Submittal of Revision to Seismic Hazard Evaluation to Include New Ground Motion Response Spectra (GMRS Using New Geotechnical Data and Shear-Wave Testing for H.B.

Robinson Steam Electric Plant, Unit No. 2., dated July 17, 2015, ADAMS Accession Number ML15201A006

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0062 Page 2 of 4

7. H.B. Robinson Steam Electric Plant Unit No 2 - Staff Assessment of Information Provided Pursuant to Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (TAC No. MF3724), dated October 19, 2015, ADAMS Accession Number ML15280A199

8. EPRI 1025287, Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details [SPID] for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, February 2013

9. Addendum to Submittal of Revision to Seismic Hazard Evaluation to Include New Ground Motion Response Spectra (GMRS) Using New Geotechnical Data and Shear-Wave Testing for H.B. Robinson Steam Electric Plant Unit No. 2, dated August 29, 2015, ADAMS Accession Number ML15243A061 10.G-190419, Rev. 7, Fuel Handling Building Piling- Plan and Details 11.G-190420, Rev. 13, Fuel Handling Building-Plan and Details at Elevation 226.00 12.G-190421, Rev. 9, Fuel Handling Building- Plan at Elevation 246.00

13. G-190422, Rev. 7, Fuel Handling Building - Plan at Elevation 275.00

14. G-190423, Rev. 8, Fuel Handling Building - Sections and Elevations 15.G-190424, Rev. 8, Fuel Handling Building - Sections and Elevations

16. G-190426, Rev. 2, Fuel Handling Building - Spent Fuel Pit Reinforcement, Sheet No 1 17.G-190427, Rev. 2, Fuel Handling Building- Spent Fuel Pit Reinforcement, Sheet No. 2 18.RNP-C/STRU-1226,"Spent Fuel Pool Structure Evaluation" 19.EGR-NGGC-0351,"Condition Monitoring of Structures", Rev. 22.

20. RNP-C/STRS-1142,"Stress Analysis for Lines 8AC-58, 8AC-58A, 4AC-59"

21. RNP-C/STRS-1141,"Stress Analysis for Line 8-AC-61"

22. RNP-C/STRS-1126,"VC Tail Piping"

23. RNP-C/SPPT-1659,"Pipe Support# AC-15-120/Spent Fuel System"

24. RNP-C/SPPT-1649,"AC-14-175 & AC-14-80 Spent Fuel Pit Cooling Piping, PM-1104 HBR-2" 25.RNP-C/SPPT-1650,"Spent Fuel Pit Cooling System AC-15-20, AC-14-125 Support Analysis"

26. RNP-C/SPPT-1651,"Pipe Support No. AC-15-60 and AC-14-155/ Spent Fuel Pit Cooling"

27. RNP-C/SPPT-1655,"Spent Fuel Pit Cooling System, AC-15-235 Support Analysis"

28. RNP-C/SPPT-1843,"SFPC System Seismic Integrity During M-1104 Modifications"

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0062 Page 3 of 4 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information per 10 CFR 50 .54(f) (Reference 1) to all power reactor licensees. Enclosure 1, Item (9) of the 50.54(f) letter requested addressees to provide limited scope spent fuel pool (SFP) evaluations.

By letter dated October 27, 2015 (Reference 2), the NRC transmitted final seismic information request tables which identified that H.B. Robinson Steam Electric Plant, Unit No. 2 is to conduct a limited scope SFP Evaluation. By Reference 3, Nuclear Energy Institute (NEI) submitted an Electric Power Research Institute (EPRI) report entitled, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (EPRI 3002007148) (Reference 4) for NRC review and endorsement.

NRC endorsement was provided by Reference 5.

EPRI 3002007148 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. This report supplements the guidance in the Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) (Reference 8), for plants where the GMRS peak spectral acceleration is less than or equal to 0.8g . Section 3.3 of EPRI 3002007148 lists the parameters to be verified to confirm that the results of the report are applicable to H.B. Robinson Steam Electric Plant, Unit No. 2, and that the H.B. Robinson Steam Electric Plant, Unit No. 2, SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

The attachment to this letter provides the data for H.B. Robinson Steam Electric Plant, Unit No. 2 that confirms applicability of the EPRI 3002007148 criteria, confirms that the SFP is seismically adequate, and provides the requested information in response to Item (9) of the 50.54 (f) letter associated with NTTF Recommendation 2.1 Seismic evaluation criteria.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

If you have any questions regarding this submittal, please contact Mr. Tony Pila, Manager (Acting)

- Nuclear Regulatory Affairs at (843) 857-1409.

I declare under penalty of perjury that the foregoing is true and correct.

Executed On: A~">+ 1120 l~

Sincerely, R. Michael Glover Site Vice President RMG/am

Attachment:

Site-Specific Spent Fuel Pool Criteria for H.B. Robinson Steam Electric Plant, Unit No. 2

United States Nuclear Regulatory Commission Serial: RNP-RN16-0062 Page 4 of 4 cc: NRC Resident Inspector, HBRSEP Unit No. 2 NRC Regional Administrator, NRC, Region II Dennis Gavin, NRC Project Manager, NRR Joseph Sebrosky, NRC Senior Project Manager, JLD-NRR

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0062 4 Pages (including cover page)

AITACHMENT Duke Energy H.B. Robinson Steam Electric Plant, Unit No. 2 Docket Number 50-261 Renewed License No DPR-23 Site-Specific Spent Fuel Pool Criteria for H.B. Robinson Steam Electric Plant, Unit No. 2

The 50.54(f) letter requested that, in conjunction with the response to NTTF Recommendation 2.1, a seismic evaluation be made of the SFP. More specifically, plants were asked to consider "all seismically induced failures that can lead to draining of the SFP." Such an evaluation would be needed for any plant in which the ground motion response spectrum (GMRS) exceeds the safe shutdown earthquake (SSE) in the 1 to 10 Hz frequency range. The staff confirmed through References 2 and 7 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the H.B. Robinson Steam Electric Plant, Unit No 2. By letter dated [Reference 5] the staff determined that EPRI 3002007148 was an acceptable approach for performing SFP evaluations for plants where the peak spectral acceleration is less than or equal to 0.8g.

The table below lists the criteria from Section 3.3 of EPRI 3002007148 along with data for H.B.

Robinson Steam Electric Plant, Unit No. 2, that confirms applicability of the EPRI 3002007148 criteria and confirms that the SFP is seismically adequate and can retain adequate water inventory for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in accordance with NTTF 2.1 Seismic evaluation criteria.

SFP Criteria from EPRI 3002007148 Site-Specific Data Site Parameters

1. The site-specific GMRS peak The GMRS peak spectral acceleration in spectral acceleration at any References 6 and 9 as accepted by the NRC in frequency should be less than or Reference 7 is 0.659g, which is ~ 0.8g, therefore, equal to 0.8g. this criterion is met.

Structural Parameters

2. The structure housing the SFP The SFP is housed in the spent fuel building, which should be designed using an SSE is seismically designed to the site SSE with a PGA with a peak ground acceleration of 0.2g (Reference 6). The H.B. Robinson Steam (PGA) of at least 0.1 g. Electric Plant, Unit No. 2, PGA is greater than 0.1 g, therefore, this criterion is met.

3. The structural load path to the SFP As shown in References 10 through 18, the spent should consist of some combination fuel pool building is a reinforced concrete structure of reinforced concrete shear wall and consists of four exterior shear walls which are elements, reinforced concrete frame 6 ft. thick. The interior divider runs in the North-elements, post-tensioned concrete South direction and it is a 4 ft. thick reinforced elements and/or structural steel concrete wall. The floor of the fuel pool is a 4.5 ft.

frame elements. thick reinforced concrete slab with clear area of 31ft. x 33.Sft. The SFP structure is supported on a 4ft. thick pile cap which transfers the load to 169 cast-in-place reinforced concrete pile foundations.

Therefore, this criterion is met for H.B. Robinson Steam Electric Plant, Unit No. 2.

SFP Criteria from EPRI 3002007148 Site-Specific Data

4. The SFP structure should be The SFP structure is included in the H.B.

included in the Civil Inspection Robinson Steam Electric Plant, Unit No 2, Civil Program performed in accordance Inspection Program in accordance with 10 CFR with Maintenance Rule. 50.65 (Reference 19), which monitors the performance and condition of structures, systems, or components (SSCs) in a manner sufficient to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions.

Therefore, this criterion is met for H.B. Robinson Steam Electric Plant, Unit No 2.

Non-Structural Parameters

5. To confirm applicability of the piping Based on References 20 through 28, piping and evaluation in Section 3.2 of EPRI valves attached to the SFP are seismic, safety-3002007148, piping attached to the related and evaluated for the SSE. Evaluation of SFP up to the first valve should have the piping satisfies allowable limits in American been evaluated for the SSE. National Standards Institute (ANSI) code for Pressure Piping ANSI B31.1, Power Piping (1967) .

Therefore, this criterion is met for H.B. Robinson Steam Electric Plant, Unit No. 2.

6. Anti-siphoning devices should be There are two items that can potentially provide installed on any piping that could hydraulic pathway for rapid drain-down of the lead to siphoning water from the spent fuel pool to a level approximately 10 ft.

SFP. In addition, for any cases above the spent fuel stored in the pool within 72 where active anti-siphoning devices hours of an earthquake occurrence: (1) The return are attached to 2-inch or smaller piping from the spent fuel pool cooling heat piping and have extremely large exchanger has a 1 in. branch line near the fuel extended operators, the valves pool normal water level. A 0.5 in. diameter hole should be walked down to confirm exists that acts as a vacuum breaker to prevent adequate lateral support. siphoning effect on the pool. The return piping is covered under the ISi program; and (2) The other item is the spent fuel pool drain line which is within 3 in. of the bottom of the pool. The drain line is prevented from draining by two closed and locked valves (one is inside the pool and the other is outside of the pool) and a blind spectacle flange upstream of the outside valve.

As described, anti-siphoning devices are installed on all SFP piping that could lead to siphoning and no active anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators; therefore, this criterion is met for H.B. Robinson Steam Electric Plant, Unit No. 2.

SFP Criteria from EPRI 3002007148 Site-Specific Data

7. To confirm applicability of the The H.B. Robinson Steam Electric Plant, Unit No.

sloshing evaluation in Section 3.2 of 2, SFP has a length of 33.5 ft, a width of 31 ft and EPRI 3002007148, the maximum a depth of 38.25 ft based on Reference 18; SFP horizontal dimension (length or therefore, this criterion is met.

width) should be less than 125 ft, the SFP depth should be greater than The H.B. Robinson Steam Electric Plant, Unit No.

36 ft, and the GMRS peak Sa should 2 GMRS maximum spectral acceleration in the be <0.1g at frequencies equal to or frequency range less than 0.3 Hz is 0.07g from less than 0.3 Hz.

Reference 6 (H.B. Robinson Steam Electric Plant Unit No. 2, GMRS submittal) which is less than 0.1g, therefore, this criterion is met.

8. To confirm applicability of the The surface area of the H.B. Robinson Steam evaporation loss evaluation in Electric Plant, Unit No. 2 SFP is 1,038.5 ft2, which Section 3.2 of EPRI 3002007148, is greater than 500 ft 2 ; and licensed reactor thermal the SFP surface area should be power for H.B. Robinson Steam Electric Plant, Unit greater than 500 ft 2 and the licensed No. 2, is 2,339 MWt per unit which is less than reactor core thermal power should 4,000 MWt per unit, therefore, these criteria are be less than 4,000 MWt per unit. met.